Changes in regulations for spray foam contractors in Canada

Late Summer 2019 - There is absolutely no doubt that Canada is the most regulated country when it comes to installation of Spray Polyurethane Foam. Manufacturers have to pass strict requirements to sell their products, part of which is having a third party Quality Assurance Provider involved in overseeing training and installation of those products.

Installers have to be trained and certified, undergoing regular audits to ensure that their skills and work practices measure up. Still there are gaps, and mistakes do occur—probably not as frequently as alarmist reporters would have you believe, but enough to make all involved understand the need for vigilance.

Perhaps the most significant gap that exists is the licensing of contractors; though manufacturers must meet strict regulations and installers fit into that framework, the role of the contractor he works for has not been as well defined. The Canadian Construction Material Centre (CCMC) is implementing changes to its evaluation partly to address that issue. For spray foam products, this change has accelerated the requirement to achieve full compliance with CAN/ULC S718 – Standard. For Site Quality Assurance Program for Spray Polyurethane Foam.

The most notable increased regulatory requirements for contractors are in the areas of business audits, active monitoring of Daily Work Records (DWRs) and accredited contractor status. The contractors need to discuss the requirements in more details with their Certification Body and start preparing themselves for these contractor audits in the coming months.

“One quality assurance provider, Caliber Quality Solutions, is currently in consultation process with its contractor members,” says Reza Haftchenari COO of Caliber, to make them aware of the impact of the requirements on the contractors. “We are actively investigating the use of technology, such as digital DWR submission, to minimize impact and cost to our contractor members. The hope is that the whole process will be enhanced with a minimum of pain.”

Contractor Audits

As part of compliance the contractor, like the installer, will be accredited by their applicable Certification Body (CB) to meet the new requirements of the CAN/ULC S718 document. This means that the contractor must allow an audit to be conducted at their physical location of business by the Certification Body and provide the files and/or documentation to demonstrate compliance with the standard.

Frequency of Audits

According to the standard, the contractor will be audited once every five years.

Audit Report

The contractor should expect an audit report from their Certification Body (CB) recording contractor compliance in accordance with the requirements of the standard. The report will identify and document any and all non-conformances of the contractor in meeting the contractor accreditation requirements. Once the report is issued the contractors have 30 days to resolve all non-conformances.

Accredited Contractor Status

Contractors achieve “Accredited Contractor” status when they can demonstrate full compliance to the requirement outlined in S718.

There are many benefits that Accreditation will bring:

The “Accredited Contractor” status can be used to differentiate contractors in the marketplace. For example, contractors may use the status in their marketing materials.
Full compliance to S718 provides assurance to building officials and end users that the spray foam will be installed consistently in compliance to the requirements of the Site Quality Assurance Program (SQAP).
“Levelling the playing field” – the contractor audit program will identify contractors that are conducting their business with unfair practices related to the quality of installation work. Contractors unwilling to comply with the basic requirements of the Quality Assurance Program will be suspended and unable to purchase material.

CCMC has made it clear that the regulatory changes in the Spray Foam Industry are being implemented this year. If you are a contractor installing spray foam in Canada you owe it to yourself to get in contact with your Certification Body to see how these changes will affect you and, perhaps most importantly, what can be done to minimize the administrative burden. The voices of contractors are important to ensure this transition is as smooth as possible so reach out and speak out.